Thanks for the chance to remark on the Division’s discussions to hyperlink the state’s Cap-and-Make investments program with these packages in existence in California and Quebec. Development Vitality is the world’s largest affiliation of biofuel producers, representing 96 U.S. vegetation that every 12 months produce 9 billion gallons of renewable gas; 114 companies related to the manufacturing course of; and tens of hundreds of biofuel supporters across the nation. Collectively, we’re working to carry higher and extra reasonably priced selections on the gas pump to shoppers, enhance air high quality, and shield the atmosphere for future generations. We stay dedicated to serving to our nation diversify our power portfolio in an effort to develop extra inexperienced power jobs, decarbonize our nation’s power combine, maintain household farms, and drive down the prices of transportation fuels for shoppers.
We respect the Division’s effort to scale back Washington’s greenhouse gasoline (GHG) emissions. Our business represents the biggest quantity of accessible, low-carbon biofuels meant to attain the aims of the Division and the State of Washington.
As we’ve outlined in earlier feedback on each the Cap-and-Make investments program and this system’s potential linkage with different carbon markets, we proceed to be involved concerning the restrictive definition of the exemption for biofuels and its affect on bioethanol. Particularly, whereas this system does comprise an exemption for biofuels, it’s restricted to solely these “fuels derived from
biomass which have no less than 40 p.c decrease GHG emissions primarily based on a full life-cycle evaluation when in comparison with petroleum fuels for which biofuels are succesful as serving in its place.”
We respect the Division’s dialogue within the ultimate rulemaking that “Ecology’s working assumption is that every one biofuels meet the 40 p.c customary for previous and close to future years except that verification course of clearly signifies in any other case.” Nonetheless, we proceed to imagine this definition within the Cap-and-Make investments program doesn’t present sufficient readability and could also be too restrictive, and in the end may prohibit the usage of sizeable volumes of lower-carbon bioethanol that might generate substantial GHG emission reductions for Washington and decrease the state’s dependence on fossil fuels.
This concern is especially vital because the Division seeks to hyperlink the Cap-and-Make investments program with these in Quebec and California the place biofuels are already clearly exempt, and the place they’ve proven to be leaders in GHG reductions in California’s low carbon gas customary (LCFS). Bioethanol and different exempt biofuels reminiscent of renewable diesel and biodiesel are cumulatively liable for 74% of California’s reductions for the reason that implementation of their LCFS. In the present day’s bioethanol represents a virtually 50 p.c discount in GHG emissions in comparison with gasoline. And as available applied sciences reminiscent of carbon sequestration and climate-smart agriculture practices are adopted, ethanol can proceed to enhance towards web zero. As an illustration, through the use of the most recent science on oblique land use change worth (ILUC) relatively than outdated and flawed knowledge, the affect of ILUC on ethanol’s carbon depth is nearer to 4 gCO2e/MJ.2 This can be a practically 80% discount from out-of-date fashions getting used.
Associated, we additionally imagine that current considerations about biofuel manufacturing on meals price and provide are unfounded. Our business produces each meals and gas. Particularly, manufacturing of bioethanol ends in all kinds of co-products, maybe probably the most important of which is high-quality animal feed that contributes on to the manufacturing of rooster, beef, pork, and different nutritious meals.
Particularly, one bushel of corn produces 2.8 gallons of bioethanol in addition to 17-18 kilos of distillers dried grains (DDGS), a extremely nutritious animal feed. Our business produces practically 40 million tons of animal feed per 12 months. That feed is equipped to meals producers right here within the U.S. and around the globe. Moreover, the renewable CO2 from bioethanol manufacturing can be essential for
meat processing, beverage carbonation, and water therapy.
Information from the United Nation’s Meals and Agriculture Group (FAO) in addition to from the U.S. Vitality Administration (EIA) additionally present within the graph beneath that the worth of meals is carefully correlated with the price of crude oil relatively than the price of corn.
